HMRC Trade Delivery Partner Round Table – Key Takeaways

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TOM key takeaways

This is the first in the upcoming series of posts on the UK Border Target Operating Model Draft.

On Thursday April 29th, Expordite® founder Kate Sukhanova attended a session for CDS software providers and operators on the Safety & Security (S&S) Target Operating Model Policy, hosted by the HMRC. This session was part of a series of engagements with international trade stakeholders and partners in relation to the new Border Target Operating Model draft.

Target Operating Model (TOM) is focused on improving imports and new import security controls and Sanitary controls. However, it’s also intended to work in parallel and together with the UK’s efforts to reach £1 Trillion of exports annually by the end of the 2020s. And the HMRC session focused on both import and export S&S documentation.

Here are Kate’s key takeaways from the session:


1. Current S&S data requirements are too extensive and not user-friendly.

S&S requirements on export apply to all goods leaving GB, irrespective of the mode of transport. According to the industry feedback, data duplication is a significant issue when completing S&S declarations.

Also, there is no user interface for lodging such declarations – an issue that’s crucial for users’ convenience. We at Expordite® are paying close attention to this when updating our CDS-compatible software.

The industry players also confirmed that having pre-populated fields would significantly reduce the administrative burden. We’ve seen this issue when we were working to integrate our software with CDS, which is why we worked to ensure that the users only have to do minimal data entry and the CDS procedure and location codes were pre-filled for the user.


2. The TOM changes to S&S controls work to minimise these admin burdens.

As confirmed in the TOM and during the HMRC session, the new S&S model will reduce data requirements to 24 mandatory fields, from 37. The full list of fields is provided on page 68 of the TOM.

Interestingly enough, the commodity code is one of the optional fields.

The timing requirements for S&S submissions vary by type of transport – but unlike customs declarations, which can be submitted after the goods’ arrival to the UK, S&S info must be received BEFORE THE GOODS’ ENTRY.

The estimated date of this change coming into force is October 2024. 


3. Entering S&S declarations through Single Trade Window will be possible.

By October 2024, it’ll be possible and easy for importers and exporters to submit the S&S info through the UK’s Single Trade Window (STW). The STW will enable information-sharing across the entire consignment and remove the need for data duplication.

In the future, the STW will allow combining S&S declarations and customs declarations, but at the moment, that’s not possible. We’ll keep a close eye on the updates from the HMRC on this matter and work to implement the necessary changes to our software at the earliest convenience.


A lot was also discussed on the STW, but in broader terms.

We’ll continue examining the Target Operating Model and providing you with bite-sized insights (in the form of text or video) about its contents and what it means for you.

Stay tuned and sign up to our mailing list!

Founder, Expordite


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